Income tax – Annual tax on enveloped dwellings. The taxpayer company had been not been carrying on a 'property development trade' as defined in s 138(4) of the Finance Act 2013 and had not been holding the relevant property for the purposes of that trade. Consequently, it was not entitled to relief from the Annual Tax on Enveloped Dwellings (ATED). Accordingly, the First-tier Tax Tribunal dismissed the taxpayer's appeal against the Revenue and Customs Commissioners' decision to impose the ATED on the taxpayer.